The regulation behind the rule
Regulation 5 of the Healthcare Services (Advertisement) Regulations 2021, under the Healthcare Services Act, prohibits before/after photos or videos in healthcare advertising outright — regardless of a disclaimer, blurring, or "results may vary" caption. The one carve-out is a doctor showing such images privately during a real patient consultation, which sits outside the definition of advertising entirely. Regulation 5 covers the same broader category of restricted claims — guarantees, comparative superiority, laudatory language — that before/after imagery falls under.
What Singapore clinics use instead
Educational content explaining the treatment itself, practitioner credentials and qualifications, and clinic environment shots. None of these imply a specific outcome, so none carry the Regulation 5 restriction. This is the same substitution principle our Singapore aesthetic clinic marketing programme builds creative around from the first draft.
How this compares to Malaysia
The same underlying restriction exists in Malaysia under KKM/MOH guidance — see our Malaysia version of this guide. Singapore's Regulation 5 is stricter in one specific way: it has no ambiguity around framing or captioning, whereas some Malaysian discussion of the rule focuses on "outcome implication." For a full cross-market breakdown across Malaysia, Singapore, Australia, Hong Kong and Taiwan, see our medical advertising rules comparison.
Other restrictions that travel with this one
Regulation 5 also restricts patient testimonials, laudatory/superlative language, guarantees and comparative claims — before/after imagery is rarely the only issue in a rejected ad. Our MOH Ad Checker runs planned copy against the full rule set, not just this one restriction.